Solid Waste & Recycling


Burning Rubber

Manufacturing Portland cement is energy intensive; producers traditionally use fuels such as coal and cleaner-burning natural gas. However, in this era of increasing energy prices, the cement industry...

Manufacturing Portland cement is energy intensive; producers traditionally use fuels such as coal and cleaner-burning natural gas. However, in this era of increasing energy prices, the cement industry is seeking alternative, cheaper fuel sources.

In Quebec, tire burning has been permitted for several years and cement plants typically charge tip fees of between $30 and $40 per tonne of tires. This equates to about $4/tonne of cement produced.

This past winter Lafarge Canada put forward a proposal to burn up to 100 tonnes of alternative fuels each day in its Bath, Ontario kiln (built in 1974). The list includes used tires, household waste, plastics, animal bone meal and other waste materials.

In addition to tip-fee revenues, the avoided cost of purchasing natural gas would save $26 for every tonne of cement produced. Lafarge estimates it will burn 2.5 million tires in the first year of operation, representing a windfall of $7 million were it to otherwise burn (cleaner) natural gas. (The savings from switching from coal would be about $2.3 million.)

While the benefit to the company’s bottom line is obvious, what remains unanswered is the cost to the environment and human health.

A precautionary approach to evaluating Lafarge’s precedent-setting proposal would be to undertake a comprehensive environmental assessment. This would include a review of its current operations and ecological footprint followed by a technical review and assessment of potential impacts. Analysis of data from other jurisdictions where similar materials are used would provide a further baseline.

However, Ontario’s environment ministry exempted Lafarge’s proposal from the provisions of the Environmental Assessment Act. Additionally, in April the minister announced the deferral of a provincial scrap-tire recycling program under Ontario’s Waste Diversion Act. Meanwhile, a true “rubber-to-rubber” scrap tire-recycling program — the Ontario Tire Recycling and Economic Development (OnTRED) plan — will remain unconsidered by the ministry.

In May, Minister of the Environment Laurel Broten told the Ontario Legislature that used-tire incineration will not affect tire recycling since it will only apply to consumer stockpiled tires that have been oxidized and thus rendered un-recyclable. However, the minister’s claims belie Lafarge’s proposal, which seeks permission to import tires and other materials from eight U.S. states and Quebec.

In fact, aggressive enforcement of tire stockpile limits has decreased the number and volume of stockpiles. Thus, there are now insufficient stockpiled tires in Ontario to sustain a business case for an approval to burn “stockpile-only” scrap tires.

In this regard the Cement Association of Canada’s February 2005 comments to the environment ministry regarding a proposed stockpile abatement program are instructive. The CAC stated that, “With no assurance of a dedicated fuel source, or a clear outline of the economics of the abatement program, cement companies cannot make the needed capital investments to participate in the program” adding that the…”declining availability of scrap tires limits our ability to make a sound business case for capital investments. We would require a 10-15 year program window to justify the investment.”

The outcome is predictable: Once Lafarge starts burning tires, other cement kilns will apply to do the same, which will eliminate opportunities for environmentally preferential rubber-to-rubber recycling in the province.

With an EA exemption and no competition from recyclers, the company can proceed with the process of acquiring a permit to burn waste under the Environmental Protection Act (EPA) — an exercise at the discretion of bureaucrats with little transparency or public consultation.

Distressing, given a local citizen recently discovered that Lafarge received dioxin-containing hazardous waste from the U.S. for incineration at its Bath kiln after querying a U.S. EPA database — a fact that hasn’t been tabled as part of the public record on Lafarge’s application. Also, while Lafarge points to its Saint-Constant, Quebec plant near Montreal as a successful operation for burning tires, Sierra Legal analysed that plant’s emissions data available through Environment Canada’s National Pollutant Release Inventory (NPRI). Between 2000 and 2004, discharges of metals such as Cadmium, Chromium, Copper, Lead, Manganese, Nickel and Zinc increased from between 100 and over 3000 percent. Particulate matter and sulphur dioxide, precursors to smog and acid rain, increased by over 100 per cent. Most significantly, over that period emissions of dioxins and furans increased by over 700 per cent.

If the company feels it has convincing solutions, it should not fear a comprehensive environmental assessment of its proposal. The local community should simply not be asked to blindly subsidize Lafarge’s bottom line with possible damage to its health and the environment..

Elaine MacDonald, Ph.D. is senior staff scientist with Sierra Legal Defence Fund. Contact Elaine at

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